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Glenn is the named the trustee of his brothers trust. According to the trust document, Glenn can distribute the income from the trust to any

Glenn is the named the trustee of his brothers trust. According to the trust document, Glenn can distribute the income from the trust to any of his brothers children, including Glenn himself. At the death of his brothers children, the trust property goes to charity. Glenn dies without making any distribution. At the time of Glenns death the value of the trust property is $5,000,000. Glenn must include $5,000,000 in his gross estate.

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